Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Page of 4886
Press 'Enter' after typing page number.
1261 to 1280 of 97705 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Transfer-pricing benchmarking requires exclusion of comparables...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and margin findings.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Transfer-pricing benchmarking requires exclusion of comparables with financially illogical gross-profit-to-sales ratios of 100 per cent or more, applying the principle that super-profit-making companies should not be retained for comparability analysis. The inclusion of four such entities was set aside and remitted to the TPO for fresh consideration after hearing the assessee. A comparable could not be rejected for non-availability of its annual report where that report had been furnished to the TPO; its inclusion in the benchmarking exercise was directed. The TPO's positive gross-profit-margin computation for another comparable was also found erroneous because the record showed a negative margin, requiring fresh determination.
Transfer-pricing benchmarking requires exclusion of comparables with financially illogical gross-profit-to-sales ratios of 100 per cent or more, applying the principle that super-profit-making companies should not be retained for comparability analysis. The inclusion of four such entities was set aside and remitted to the TPO for fresh consideration after hearing the assessee. A comparable could not be rejected for non-availability of its annual report where that report had been furnished to the TPO; its inclusion in the benchmarking exercise was directed. The TPO's positive gross-profit-margin computation for another comparable was also found erroneous because the record showed a negative margin, requiring fresh determination.
Note: It is a system-generated summary and is for quick reference only.